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Postal Rate and Fee Changes, 2000
Docket No. R2000-1
RESPONSE OF THE UNITED STATES POSTAL SERVICE
WITNESS BARON TO ADVO INTERROGATORIES
(ADVOIUSPS-T12-1-5)
The United States Postal Service hereby provides the response of witness Baron
to the following interrogatories of Advo, Inc.: ADVOIUSPS-Tl2-I-5.
filed on February
22.2000.
Each interrogatory is stated verbatim and is followed by the response.
Respectfully submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
475 L’Enfant Plaza West, S.W.
(202) 268-2993; Fax: -5402
Washington, D.C. 20260-l 137
March 7.2000
RESPONSE
OF UNITED STATES POSTAL SERVICE WITNESS BARON TO
INTERROGATORIES
OF ADVO. INC.
ADVOIUSPS-T12-I. With respect to the FY98 accrued activity time proportions
developed in LR l-159 from the Engineered Standards (ES) data collection, please
provide any information you have on the following:
(a) Statistical measures of accuracy or reliability available on the estimates of annual
proportions of accrued activity time for each route sampled.
(b) Statistical measures of accuracy or reliability available on the estimates of the
annual proportions of accrued activity time for each route type for each zip sampled.
(c) Statistical measures of accuracy or reliability available on the estimates of the
annual proportions of accrued activity time for each route type for each region
sampled.
(d) Statistical measures of accuracy or reliability available on the estimates of the
annual proportions of accrued activity time for each route type for the USPS city
carrier system in its entirety.
RESPONSE:
(a) through (d). I have not produced any statistical measures of accuracy or reliability.
1
RESPONSE
OF UNITED STATES POSTAL SERVICE WITNESS BARON TO
INTERROGATORIES
OF ADVO. INC.
ADVOIUSPS-TI2-2. With respect to the FYg8 accrued activity time proportions
developed in LR-I-159 from the Engineered Standards (ES) data collection, did you, in
any way, attempt to quantitatively validate these proportions with data from other
sources? If so, please explain fully, and provide your analyses and results.
RESPONSE:
No.
2
RESPONSE
OF UNITED STATES POSTAL SERVICE WITNESS BARON TO
INTERROGATORIES
OF ADVO. INC.
ADVOIUSPS-T12-3. On page 31 of your testimony, you provide explanations for the
terms Loading, Driving, Route-Access (FAT), Route-Access (CAT), and Collection
Activity Categories. Prior to performing your analysis and submitting your testimony, did
you review the Engineered Standards data set and attempt to:
(a) Ensure that the Engineered Standards tally assignments to those activities matched
precisely your definitions? If so, please explain what you did, and identify any
concerns you may have with respect to the precise matching of any Engineered
Standards tally (or set of tallies) with your ratemaking definitions.
(b) Check Mr. Raymond’s assignments to various activity times in order to determine
whether they were consistently applied? If so, please explain fully and identify any
concerns you may have with respect to consistency of application.
(c) Ensure that the definitions applied to the Engineered Standards data (and the times
that were ascribed to them) correctly matched the ones used in the FAT, CAT, and
LTV data collections? If so, please explain them.
RESPONSE:
(a) I did conduct such a review. I communicated to Mr. Raymond the definitions of the
six street activity categories: load time, driving time, street support, route/access FAT,
route/access CAT, and collection box. I observed that these definitions are the ones
summarized in the “Cost Segment 7” section of what is now Docket WOOO-I, USPS
LR-I-l, Po stal Se rvice ’s Su mm arv Descriotion of USPS Develooment of Costs Bv
Seaments And Comoonents. FY 1998.
The major concerns I discussed with Mr. Raymond were the need to define load
time as time that begins only after the carrier has completed accessing a delivery stop,
and to define the activity of walking to or driving up to a delivery stopping point as
something other than load time (specifically, as route/access FAT walking time, driving
time, or route/access CAT time). In particular, I wanted to ensure that Mr. Raymond
would define street-time tallies as load-time tallies only in those instances in which the
carrier is physically stopped at a delivery stopping point doing one of the following:
3
RESPONSE
OF UNITED STATES POSTAL SERVICE WITNESS BARON TO
INTERROGATORIES
OF ADVO, INC.
(1) putting mail into a receptacle, or preparing to do so through the handling of
mail pieces, bundles, or mail-related equipment (e.g., by fingering mail to get
it ready for delivery).
(2) collecting mail from receptacles.
(3) obtaining signatures from and communicating with customers in the process
of delivering accountable services.
My communications with Mr. Raymond also emphasized that any activity of handling
mail or mail-related equipment that occurs at a stopping point other than a customer
delivery location should be identified as a street support or route-access FAT activity,
not as load time. An example is the handling of mail or mail-related equipment at a
vehicle stopping point in preparation for the activity of walking on the loop section of a
route.
(b) I did perform such a check. I observed several records in the ES database that
showed questionable allocations of tallies to the load-time activity. I questioned Mr.
Raymond in particular to verify that the carriers being observed in these instances were
correctly identified as being located at a delivery stopping point in the process of either
putting mail into receptacles or preparing to do so. I received assurances from Mr.
Raymond that this was indeed the case in all such instances.
(c) It is my understanding that the definitions I communicated to Mr. Raymond are
consistent with the definitions that had been used in the CATFAT and load time studies.
RESPONSE
ADVOIUSPS-T12-4.
this rate case:
OF UNITED STATES POSTAL SERVICE WITNESS BARON TO
INTERROGATORIES
OF ADVO. INC.
With regard to the Engineered Standards data set and its use in
(a) Please describe all issues that you discussed with Mr. Raymond and when they
were discussed.
(b) Please provide all written guidance and describe all oral guidance you gave Mr.
Raymond on how to ascribe tallies to the Drive, Load, FAT, CAT, Collection, and
Street Support categories.
(c) Please describe the types of Engineered Standards tallies that you assisted Mr.
Raymond to identify in terms of Drive, Load, CAT, FAT, Collection, Street Support.
RESPONSE:
(a) The issues I discussed with Mr. Raymond were the definitions of the street-time
activity categories, alternative methods of using data from the ES database to estimate
percentages for these categories, and the application of these percentages to the
distribution of accrued street-time cost across activities. These discussions were held
from March through April 1999, and again from November 1999 through January 2000.
(b) It is my understanding that all written guidance provided to Mr. Raymond came from
USPS staff. The oral guidance I provided Mr. Raymond consisted of review and
clarification of the street-time activity definitions to help ensure that Mr. Raymond would
accurately assign work-sampling tallies across the six major street-activity categories.
(c) The types of tallies that I assisted Mr. Raymond in identifying were those that raised
questions regarding the relationship between the location and activity of the carrier and
the allocation of activity tallies to street-activity categories. My assistance consisted of
guidance relating to how the combination of the physical location and the activity
conducted by the carrier at the time a tally was being recorded should be interpreted for
purposes of allocating the tally to the appropriate activity category.
5
RESPONSE
OF UNITED STATES POSTAL SERVICE WITNESS BARON TO
INTERROGATORIES
OF ADVO. INC.
ADVOIUSPS-T12-5. Did you independently review the Engineered Standards data set,
prior to Mr. Raymond’s activity category assignments, and attempt to assign them
yourself? If so, please explain how many route-days of data you reviewed and whether
you had any difficulties in making the assignments.
RESPONSE:
I did independently review the Engineered Standards data set prior to Mr. Raymond’s
activity category assignments. I reviewed 881 route-days of data. I did not attempt to
independently assign tallies to activity categories prior to Mr. Raymond’s decisions on
these assignments.
6
DECLARATION
I, Donald M. Baron, declare under penalty of perjury that the foregoing answers are true
and correct to the best of my knowledge, information, and belief.
#. dLwlJ
Date: 3 - 7- 0 0
-.
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing document upon all
participants of record in this proceeding in accordance with section 12 of the Rules of
Practice.
/&ZL
Richard T. Cooper
475 L’Enfant Plaza West, SW.
Washington, DC. 20280-l 137
March 7,200O